Checkpoint selection is a routine decision in supervised fine-tuning (SFT): training produces multiple checkpoints, but only one is retained. Yet fixed-budget comparisons do not by themselves distinguish three empirical claims: whether more validation data improve checkpoint selection, whether a selection rule outperforms validation-loss selection, and whether it improves over simply retaining the final checkpoint. We therefore treat checkpoint selection as a finite-information decision problem. Holding completed training trajectories, candidate checkpoints, and independent test items fixed, we vary the validation budget and separately measure improvement from additional validation data, gain over negative log-likelihood (NLL) selection, and gain over the final checkpoint. Across 60 mathematical SFT trajectories and 19 configurations, increasing the validation budget from 32 to 305-313 examples raises independent-test accuracy by 0.32 percentage points (pp) for generated-accuracy selection and 0.29 pp for checkpoint agreement, with 95% configuration-bootstrap CIs of [0.10, 0.56] and [0.11, 0.50], respectively. At the full validation budget, the two generation-based rules outperform matched NLL selection by 0.71 and 0.85 pp, respectively, while their gains over the final checkpoint remain unresolved. A cross-domain replication on 12 newly trained Commonsense trajectories shows the same qualitative separation: increasing the validation budget from 32 to 1,024 questions improves generated-accuracy and checkpoint-agreement selection by 0.87 and 0.27 pp, while gains over the final checkpoint again remain unresolved. Together, these results show that benefiting from more validation data, outperforming NLL selection, and outperforming the final checkpoint are distinct empirical claims that require separate evidence.

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